| November 3, 1989 | |
| Mr. R.M. Beith | Current Amendments and |
| Senior Advisor | Regulations Division |
| Fiscal Policy and Technical | D.C. Burnett/957-2078 |
| Interpretations |
24(1)
This is in response to your request for our views on whether we can credibly persuade that the problem is soluble and workable.
24(1) has expressed concern with the need to implement extremely complex and newly designed accounting procedures to meet the requirements of the proposed regulations.
21(1)(b)
While we recognize the complexity of making a CCA calculation for each asset, we do not think this would require a separate entry on the CCA schedule for each asset. Taxpayers should be allowed to show all their specified leasing property owned at the end of the year on one line of the CCA schedule. A separate line would be needed for all such property disposed of during the year. Needless to say the taxpayer would be required to maintain adequate records, including electronic data processing media, to permit our auditors to verify the CCA calculations.
We agree with the comments in the memorandum signed by K.C. McLean with respect to the taxpayers' ability to comply with the new rules.
B.J. BrysonActing Director Current Amendments and Regulations Division